Property can only be traced if it is identifiable. If it has been dissipated, e.g. spent on food, drink or a holiday, it will no longer be identifiable and cannot be traced. Similarly money paid into an overdrawn bank account (Bishopsgate Investment Management v Homan [1995] Ch 211) or spent paying off other unsecured debts (as in Re Diplock) cannot be traced. Indeed, if S tries to create a trust of his money by sending his cheque to T Ltd expressly so that the money will be held on trust for him, no trust ever arises if the money was lost by payment into an overdrawn bank account: Re BA Peters plc [2008] EWCA Civ 1604.